Treasury officials have pledged to provide relief in certain areas from the unpopular final regulations on foreign tax credits. Jose Murillo, deputy assistant secretary for International Tax Affairs, said that Treasury will propose regulations with a safe harbor for royalty withholding “probably in a matter of months.”
Treasury is also looking at clarifications or technical corrections on the cost-recovery requirement and may issue guidance on disregarded distributions, though that may “be not in the near term.”
For more information on the final FTC regulations, see our Tax Flash, “Final FTC regs address broad range of issues.”
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